FAQs on new OSHA Fall Protection Regulations: Vol. 2 – Roof Work

This second entry in our blog series on new OSHA fall protection regulation focuses on common questions related to low-slope roof work. See Volume 1 for information on safe working distance from a roof edge.

This photo shows an example of a way to protect employees traveling from an access point to a work area.

How do we protect workers when accessing and traveling to a work area on a low-slope roof?

From a strict interpretation of OSHA language, conventional fall protection is always required from 0-6 feet of the roof edge. If you have an access ladder at the roof edge on a low-slope roof, conventional fall protection is required from the roof edge to the safe distance for the given situation (frequent/infrequent). On the other hand, this is not specifically addressed, so OSHA may clarify this issue in the future through various compliance documents that another option may be permissible. Nothing in the commentary or subsequently published information provides any additional guidance at this time.

What are the rules for warning lines? Is a painted line at 6 feet from the roof edge compliant?

The specific requirements for the warning line as part of a designated area can be found in 29 CFR 1910.29(d)(2). A warning line serves as a reminder that there is a roof edge, so that the employee will stop well before approaching the edge. When installed properly, the warning line is meant to come into physical contact with a person allowing them to stop in time. OSHA states that employers must ensure that the warning line has a minimum tensile strength of 200 pounds. Please note: despite being the same magnitude of 200 pounds, this is not the same load that a guardrail is required to support. Due to tensile strength requirements, a painted line is not compliant as a warning line.

Do references to safe distance and allowance for a designated area apply just to roof edges or to any unprotected edges?

Although the actual definition of a designated area mentions “any walking/working surface,” all of the guidance for how designated areas are to be applied and used are related to low slope roofs – found in OSHA 1910.28 (b)(13). The regulation does provide specific guidance for edge protection near pits more than 10 feet deep – in OSHA 1910.28 (b)(8).

Please subscribe or check back next Wednesday morning for the next installment in this blog series. And, if you have your own specific questions, please comment below.

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